Sep 5

From Raw to Refined: How UAE’s New Rules Expand Qualifying Commodity Trading

On 3 September 2025, the Ministry of Finance issued Ministerial Decision No. 229 of 2025, repealing MD 265/2023. This decision widens the scope of Qualifying Activities for Free Zone Corporate Tax purposes. The most impactful change? The removal of the words “in raw form.”

That means companies trading not just in raw commodities, but also refined products, associated by-products, and even environmental credits can now qualify for the 0% QFZP rate — provided their pricing is linked to a recognised quoted benchmark.

📌 Practical Examples

  • Fertilizer traders dealing in urea (HS 3102) are in scope, as benchmarks exist on Platts and Argus.
  • Steel billet traders storing goods in JAFZA can qualify, provided that logistics revenue stays under 51% of total revenue.
  • Carbon credit traders are now explicitly covered, as agencies like Montel and Expana are named in MD 230/2025.

Why This Matters

Without clear evidence of quoted prices from exchanges or recognised price reporting agencies, companies risk losing their 0% tax rate. The FTA expects audit-ready files showing HS classification, benchmark references, and contract pricing clauses.

Key Takeaways

  • “Raw form” is gone — refined and processed commodities can now qualify.
  • Every qualifying product must be linked to a recognised quoted price.
  • Maintaining HS mapping + contract benchmark references is non-negotiable.

How Fastlane Tax Consultancy Can Help

At Fastlane, we translate these new rules into action:

  • HS Code Mapping: We classify your commodities correctly under UAE Customs & HS chapters.
  • Quoted Price Verification: We cross-check Platts, Argus, ICIS, Fastmarkets, Montel, Expana, and others to confirm your products have recognised benchmarks.
  • Contract Clause Updates: We insert benchmark references into your contracts so they stand up to FTA scrutiny.
  • Audit-Ready Pack: You get a complete compliance file — HS codes, benchmark evidence, contract extracts — ready for inspection.

With these safeguards, you keep your 0% QFZP rate intact while confidently expanding your commodity trading portfolio.

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